Orange County Tax Attorney Blog

The Value of a Tax LLM After Your First Job: Part 2.2 of “Is Getting a Tax LLM a Good Idea?”

In an earlier post, I discussed whether a tax LLM was worth the cost largely as a function of its affect on landing one’s first tax […]

FINCEN to Allow Automatic Extensions of FBAR Deadline

As noted in a prior post (here), H.R. 3236 became Public Law No. 114-41 and provided several directives to the Secretary of the Treasury to issue regulations providing […]

United Way’s Volunteer Income Tax Assistance Program in Orange County Needs Volunteers

The Orange County Register put out an article last (click here) week highlighting the United Way of Orange County’s need for volunteers for the upcoming tax […]

7th Circuit Court of Appeals Issues Ruling to Limit Tax Court Jurisdiction to Invalidate Levies

On November 18, the Seventh Circuit issued its opinion in Adolphson v. Commissioner, in which it upheld the ruling of Tax Court Judge Carluzzo in the […]

IRS Changes Procedures to Deny In-Person and Face-to-Face Conferences

In yet another blow to taxpayers, the IRS has amended its Internal Revenue Manual, which provides procedures for its employees to follow, to deny the right […]

Ecigarette Sellers To Be Subject to Registration Requirements for Cigarette and Tobacco Products Retailer Licenses Starting January 1 2017

The California State Board of Equalization issued a press release on November 2, 2016, advising “E-Cig” sellers of the new license registration requirements starting on January […]
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Does the IRS Have Discretion to Apply Lower FBAR Penalties?

Does the IRS Have Discretion to Apply Lower FBAR Penalties? On May 13, 2015, the IRS issued a memorandum to all IRS LB&I, SB/SE, and TE/GE […]
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What Actions Extend the Length of the IRS’s Time to Collect?

What Actions Extend the Length of the IRS’s Time to Collect? Under the general rule, the IRS must collect taxes within 10 years of the date […]

When Are Legal Fees Deductible as Employee Business Expenses?

When Are Legal Fees Deductible as Employee Business Expenses? In Guill v. Commissioner, 112 T.C. 325 (1999), the United States Tax Court succinctly explained the deductibility […]
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When Is a California Tax Attorney’s Conflict of Interest Unwaivable?

When Is a California Tax Attorney’s Conflict of Interest Unwaivable? A court may find that a conflict of interest by a California attorney may not be […]
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Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess?

Does Filing an Amended Tax Return Extend the IRS Statute of Limitations to Audit or Assess? In general, the filing of an amended return does nothing […]
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Bedrosian v. United States – FBAR Wilfullness Penalty Standard Considered by Third Circuit Court of Appeals

Recent Tax Opinion Highlight: The opinion of United States Court of Appeals for the 3rd Circuit in Arthur Bedrosian v. United States, a recent FBAR willfulness penalty […]

Kimble v. United States, Court of Claims No. 17-421 – FBAR Willfulness Penalty Case

The below is the HTML text of the original opinion in the Kimble v. United States opinion in the United States Court of Claims, a wilful […]

The IRS’s Laguna Niguel Office – Where IRS Attorneys, Revenue Agents, and Criminal Special Agents Work

The IRS’s Laguna Niguel Office – Where IRS Attorneys, Revenue Agents, and Criminal Special Agents Work If you have ever been to the “Ziggurat,” you never […]
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I Quit My Federal Prosecutor Job Because of a Government Shutdown

I Quit My Federal Prosecutor Job Because of a Government Shutdown: My Story. When I was offered a line-attorney job at the U.S. Attorney’s Office for […]
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What Is an IRS Tax Assessment?

What Is an IRS Tax Assessment? An IRS tax assessment is a bookkeeping entry made by the Internal Revenue Service when an IRS assessment officer signs […]